Representation by Wiltshire Council (Wiltshire Council)
- Date submitted
- 11 January 2019
- Submitted by
- Local authorities
The text below is the Executive Summary of a more comprehensive response, which will be submitted via email separately.
Wiltshire Council is the host authority for the A303 Amesbury to Berwick Down Scheme and statutory consultee within the Development Consent Order (DCO) process.
The Council reiterates its support for the Scheme and corridor-wide improvement in principle, subject to the resolution of the issues raised herein. However, as the DCO represents the outline design for the Scheme, additional details will emerge during the Examination and development of detailed design. Therefore, the Council reserves the right to amend its position as further information and clarity becomes available.
The Council will seek recovery of costs incurred through a Planning Performance Agreement or the DCO.
The issues identified within this response are intended as a summary to assist the Examining Authority in identifying the principle issues to be considered at Examination. Detailed information will be submitted within the Council’s Written Representation, Local Impact Report and Statement of Common Ground.
Highways and Transport
As Highways Authority, further clarity and consideration is required on the proposed operation of and responsibilities for specific elements of the Scheme. These include:
a) Traffic controls at Countess and Longbarrow roundabouts b) Maintenance responsibility for carriageways and signal controls c) De-trunking proposals i.e. at Countess Roundabout and at layby to west of Winterbourne Stoke d) Road (re)classifications e) Precise boundaries to the new highway for which it is the vesting authority along with details for the associated support infrastructure f) Speed limits for the realigned section of Allington Track g) Provision of commuted payments.
Identified inconsistencies within the documentation will also need to be addressed i.e. the description of the length of the new and improved A303 trunk road and contradictions between the core working hours stated within the REAC tables and those used within TA assumptions.
The REAC tables require further detail to address issues of concern, e.g. a pre and post works condition survey and for regional diversion measures to be provided. The Council also requires enforceable measures to be included to deter haulage sub-contractors using unsuitable routes.
Archaeology and World Heritage
As the DCO portrays an indicative design, the lack of design detail restricts the ability to fully assess the impact of the Scheme on cultural heritage, landscape setting and the need for mitigation.
The Environmental Statement is incomplete and requires amendment as the archaeological field evaluations were completed after submission. Furthermore, the number of non-designated heritage assets adversely impacted by the Scheme should be conveyed as the minimum; many features are likely to be revealed during the mitigation phase and construction.
The Outline Archaeological Mitigation Strategy (OAMS) is lacking detail and should include the results from all archaeological evaluations. Better cross referencing is required between the OAMS and the Outline Environmental Management Plan (OEMP). The Detailed Archaeological Mitigation Strategy (DAMS) should be agreed before consent for the Scheme is given.
Additional mitigation is required to minimise the adverse impacts of the dual carriageway in cutting on the setting of asset groups in the western part of the World Heritage Site (WHS), especially the Winterbourne Stoke and Diamond Group.
Green Bridge No. 4 is insufficient to mitigate the potential visual impacts caused by the cutting on key monument groups with attributes of OUV, primarily the Winterbourne Stoke, Diamond Group and Normanton Down Group. Highways England are encouraged to explore further design options to help minimise the adverse impact or consider extending the tunnel (either bored or cut and cover).
Consideration should be given to the design of the Longbarrow junction and dumbbell roundabout at Oatlands Hill to minimise impact on the prehistoric settlement remains. The potential for light spillage and adverse impacts on dark skies within the vicinity of the WHS boundary is of concern.
The imposition of restrictive covenants on groundworks on land above the tunnel is concerning as it may restrict archaeological investigations in a core part of the WHS.
The inclusion of a detailed archaeological and heritage outreach and education programme within the DAMS should be referenced in Requirement 5.
Flood and Drainage
The modelling approaches are generally found to be sound. However, additional information and model runs, including the rectification of inconsistencies and omissions are required during Examination.
The 539m long, 5m deep culverting of the watercourse within the pluvial model may not be supported by the Council due to detrimental environmental, health and safety aspects and maintenance impacts.
The road drainage strategy is high-level and lacking in detail.
The reports would benefit from a more consistent approach when modelling the effects of climate change and better cross-referencing across the various documents to ensure there is greater consideration of the combined effects and shortfalls in each stage of the design.
The preliminary and temporary works (as detailed within the OEMP) will take 6 years to complete (2020-2026), therefore the impact on flood risk could be significant. However, the OEMP is light on detail and high-level at this stage. It is essential that the Council are consulted, and given sufficient time, for the approval of the Construction Environmental Management Plans (CEMPs), and as part of the discharge of requirements, to ensure that flood risk is managed during the construction period.
Public Protection
It is queried whether additional measures are proposed at locations identified in the Environmental Statement (ES) as having large adverse cumulative effects. Clarity should be sought on core working hours due to discrepancies and a definition of summer and winter for earthworks working hours is required. Consultation is required with the Council as concrete batching is a Local Authority permitted process, unless exempted. The Council and Environment Agency should receive reports on further ground investigation works, together with any mitigation proposals. Works notices should be notified to the Council. Clarity is sought on power provision to the satellite compounds, use of chainage for locations, and CRM and EM roles. Further details are required of the measures to divert the Esso pipeline.
Air quality monitoring should be agreed with the Council. Clarification is also required regarding Quidhampton and the severe adverse effects on Salisbury AQMAs identified in the ES, proposed haul routes and their proximity to receptors and whether any water from the slurry treatment plan will be tankered to the Salisbury Waste Treatment Works. A number of amendments to the REAC tables will also be required i.e. extension to BPM to include other means as may be required. Reference should be made to the IAQM Guidance on Air Quality Monitoring in the Vicinity of Demolition and Construction Sites. Furthermore, arisings must be spread and managed so as not to cause a statutory dust nuisance.
The Council should be notified if agreed vibration levels are exceeded. The Council needs to be consulted on the Noise and Vibration Management Plan. Detailed assessment should be conducted for the property Lindisfarne in Ratfyn Road and consideration given to the potential relocation for Stonehenge Cottages inhabitants over the 2 x 7 day construction periods. Details of the noise receptor north of Winterbourne Stoke is unclear.
The Council is commissioning an external review of the air quality, noise and vibration models.
Clarity is required on whether the contractor will be required to report any accidental spillages affecting the groundwater or private water supplies and whether human health / consumers of private water supplies have been considered as a receptor. Wiltshire Council should be informed in case of groundwater contamination.
Ecology and Landscape
It is imperative that sufficient good working practices and forward mitigation are in place for all preliminary works. There are potential issues around contamination, utilities diversion and minor highways works that should be specifically covered within the OEMP to prevent ecological impacts.
Further consideration is required to better understand the temporary adverse impacts (construction phase) and the residual effects upon visual amenity at either end of the tunnel, especially the Till Viaduct and Countess flyover.
Public Rights of Way
Detailed proposals for the rights of way and access changes are required including surfacing, width, signage and waymaking, structures to provide access to non-motorised users and motorised vehicles, private means of access, boundary fencing / hedging, fencing of Green Bridges against drops, and verge treatment. Further information on junction layouts, three proposed routes and stopping-up proposals is also required.
The severed link between AMES11 and AMES12 for motorised users creates a breach of Wiltshire Council’s statutory duty under s.130 Highways Act 1980. The Council considers the need for a prohibition of driving order for motor vehicles to be Associated Development due to Highways England’s decision not to provide an alternative link between the two byways. It should be included within the DCO.
The Council must approve the design, construction details and specifications for all diverted and new sections of PROW maintainable by the Highway Authority prior to commencement of works (along with any commuted sums).
Where temporary diversions or closures of PROW become necessary, construction details of alternative routes must be agreed in advance with the Council.